The Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight granted no action relief to swap dealers that enter into certain replacement swaps with certain structured finance special purpose vehicles that are triggered by a credit downgrade of a swap dealer. The relief extends solely to new swaps entered to replace old swaps that were consummated on or before October 10, 2013. In connection with such transactions, swap dealers are exempt from complying with certain of the Commission’s business conduct and documentation requirements. The replacement swap may not alter the material terms of the original swap agreement.